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Web Accessibility : What Your Campus Needs to Know
Diane Kubarek, Tracy Mitrano, Cyndi Rowland, Sharon Trerise
Overview of Laws Overview of Laws Affecting Web Affecting Web AccessibilityAccessibility
Cyndi Rowland, Ph.D.
WebAIM, Utah State University
A Little about myself . . .
Cyndi Rowland, Ph. D.Associate Director-CPD
National Center on Disability & National Center on Disability & Access to EducationAccess to Education
WebAIM WebAIM (Web Accessibility In Mind)(Web Accessibility In Mind)
Utah State UniversityUtah State University
• Although an accessibility expert, I am NOT a lawyer. If you seek Although an accessibility expert, I am NOT a lawyer. If you seek legal advice, please contact institutional counsel or an attorneylegal advice, please contact institutional counsel or an attorney
SUMMARYSUMMARY
• Rehabilitation Act (Sec 504 & 508)• ADA of 1990
– see 28 C.F.R. Part 35– Dept of Justice ruling (9/9/96): ADA accessibility
requirements apply to Internet web pages (10 NDLR 240)
• Telecommunications Act (see Sec 255)• Responses from U.S. Dept of Ed, OCR (see
docket numbers 09-95-2206; 09-97-2002)
• NIMAS (in IDEA)
Review• Rehabilitation ActRehabilitation Act
– Section 504 (all federally funded programs)
– Section 508 (federal agencies)
Section 504 of the Rehabilitation Act
“ no otherwise qualified individual with a disability in the United States… shall, solely by reason of his disability, be
excluded from the participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving federal financial
assistance. . .” (29 U.S.C. Section 794)
Review
• Rehabilitation Act–Section 504 (all federally funded
programs)• Affirmative obligation to plan in
advance • Courts knocking down post-hoc
accommodations
• Reactive, rather than proactive, model
• Native access can be achieved in many cases, yet the model reinforces “accommodation”
• Mindset of many is to go to DSO or SpEd and they’ll do it. They may not have the expertise or see the big picture.
504 Model for working with students may not fit Web
Section 508
Section 508 of the Rehabilitation Act of 1997 provides the legislative language for accessible electronic information technology, including the Internet
Took effect: June 21, 2001
Review• Rehabilitation Act
– Section 508 (federal agencies)• All the buzz years ago, lost it’s luster• Interpreted NOT to apply to states with Tech Act
monies• Used to define floor of access (16 standards) • Emerging in federal RFP’s and contracts, emerging
as procurement language • VPAT’s continue to be problematic• Monitoring is poor, (benign neglect?)• “Access” still means different things (e.g., FAFSA)
– ADA of 1990 • Civil Rights Legislation• Word “Internet” not in ADA • Employment discrimination• Title II: effective communication• Title III: place of public accommodation • Sample court cases
– MARTA, Southwest, Utah DOJ – CSU Fullerton, UC Berkeley, Cappella College– Target
• Current draft of ADAAG guidelines do not include any mention of electronic information (other than ATM’s and Kiosks)
Review
ADA may help us think about electronic access
• Right to access entire building– Rights to independence– Back doors problematic
• Could not go around ADA by “renting” inaccessible buildings• Remodel “springs” law into place
– Legacy pages
• Written transition plan necessary • Regulations began to inform professions (e.g., architects,
engineers, building inspectors)
• Telecommunications ActTelecommunications Act (see Sec 255)– Applies to hardware, – Excludes the Internet – What will happen to telecom as VoIP takes a place in the market?
• IDEAIDEA– NIMAS / NIMAC– Could this foot in the door creep to NCLB? (AYP could help)
• Higher Ed ActHigher Ed Act– Don’t get your hopes up
• Miscellaneous legislationMiscellaneous legislation that may assist in making the case– Air Carrier Act– HAVA
Review
• StatesStates– 17 with laws that cover Web– 8 with policies– Most using 508 or hybrid– Vendors nightmare– Many do not include education
• EducationEducation– Lots of models & good work being done
• Postsecondary policies all over (See WebAIM)• K-12 (e.g., Texas, Oklahoma, Kentucky, CoSN)
Review
Don’t forget international accessibility laws
Globalization realities in distance education
(a.k.a. The world is flat)
Questions or comments?
Policy, Process, and Policy, Process, and History of Web History of Web
Accessibility at CornellAccessibility at Cornell
Tracy Mitrano
Director of IT Policy and Computer Policy and Law Programs
Big “P” and Little “p” Policy
• Big “P” policy involves external issues, such as national security, electronic surveillance laws, digital copyright or disability law.– Rehabilitation Act – Americans with Disability Act– How many tax dollars should be spent on
people with disabilities?
• Graphic representation of Laurence Lessig’s foundational concept of the principle influences on the Internet, as described in his book, Code, published in 1999. This graph is offered with the suggestion that institutional policy is similarly influenced by market, social norms, technology, and the law.
MarketMarket
ArchitectureArchitecture
Norms Norms
LawLaw
Policy Policy
The four major influences on institutional policy
Big “P” and Little “p” Policy
• Little “p” policy is institutional policy.– Preservation and protection of institutional
interests and assets -- including reputation!• “Any person, any study”
• Cornell Model• Centralized University Policy Office
– http://www.policy.cornell.edu/
• Famous “policy on policies!”– http://www.policy.cornell.edu/vol4_1.cfm
Take Aways about Institutional Policy
• Policy is integral part of the culture and traditions of each individual institution.
• Matters less who or how institutional policy is developed than that some process exists…
• Process breaks down into three parts– Initial high level send off with guidance– Middle level review and/or stakeholders– Executive sign off
Cornell’s Policy Process• This process boils down to three steps: an introductory step, where a
responsible office brings a policy concept to the Executive Policy Review Group, which represents the highest level of the University administration. This group reviews the policy as a concept, offers direction where needed, and either approves or denies the responsible office to go forward to draft and vet a policy throughout the University community. The second step is review by the Policy Advisory Group, which represents mid-level administrators whose principle role is to determine optimal implementation, and therefore the focus is largely on procedures. The Policy Advisory Group is not allowed to reject the policy as a concept, and only in extreme situations could they reject the policy for failure of appropriate implementation. Given their role in reviewing all University policy, PAG also assists in harmonizing policies into the University policy library. The third and final step is review by the EPRG to assure that the policy meets their original expectations, has been reviewed by the PAG and all other relevant stakeholders, and is in final draft form in order for the University policy office
to promulgate it to the entire University.
References
• Information Technology Framework– http://www.cit.cornell.edu/oit/policy/framework-chart.html
This diagram illustrates the development of IT policy in the period from 2002 projected into 2007. It breaks down the original responsible use policy, promulgated in 1995, and one of the first IT policies at the University level in the country, into discrete digestible full-text policies. The left-hand side of the diagram represents, in the main, security policies, and the right hand side, privacy policies, augmented by other IT issues to be resolved at the University level through policy, such as domain name conventions and Web accessibility.
• Impact Statement for University Policy 5.11, Accessibility of Cornell Web Sites– http://www.cit.cornell.edu/policy/drafts/WAis.pdf
Defining Scope for Cornell’s Proposed Policy on Web
AccessibilityDiane Kubarek
Director, Office of Web Communications
Cornell’s scope definition(to-date)
• New definitions categorize Cornell Web sites• Most (not all) official sites must be compliant,
eventually• Unofficial sites are encouraged to comply• Some sites have as long as 5 years to come into
compliance (mitigation of impact)• There will be a process for undue burden
exemption requests
“Sticky Wickets”
• Which standard?
• How do we define the University Web space? (Scope step 1)
• How do we define priorities within that Web space? (Scope step 2)
Which standard: Why Section 508?
• 508 is less “fluid” (W3C is under active revision)
• Tools exist to assess 508 compliance (hybrids imply tools require more interpretation)
• Future legal actions more likely to be based on 508 than W3C or hybrids
Defining the Web space: basic definitions (see Impact
Statement • Defining a site (p.2)
• Categorizing sites as “official” (pp.2-3) or “unofficial” (p.5)
• Capturing all the major types of sites
• Deciding on appropriate exemptions (p.3)
Defining the Web space: sites for special consideration
• Course sites• Archival sites• Student organizations• Student project sites (class assignments)• Sites about individuals - personal, professional• Affiliated organizations - e.g. alumni classes &
clubs• Testing or staging sites• “Live” sites (e.g. Webcasts)
Defining the Web space: sites for special consideration
• Sites developed to experiment with new technologies
• Sites you host for the “general good” – WWW Virtual Library catalog sites– Professional organizations or associations– Mirror sites
• “Dot Orgs”, “Dot Coms”, and other official sites outside of your domain name space, or hosted externally
Defining priorities: hard questions
• Internal vs. external
• Retrofit vs. redesign (from this day forward)
• Password protected vs. not
• Is traffic volume a consideration?
• What’s realistic at your institution?
• All reflected in implementation schedule
Defining priorities: policy questions answered
by your culture• How will exemption requests be reviewed?• In your policy process, who bears the burden of
enforcement?• Can you influence purchasing decisions?• Can you promote skill elevation in job
descriptions during Web developer hires?• How will you define success?• How will you monitor success?
Current Cornell challenges
• Research sites (collaboration, data-gathering)• Faculty issues, especially course sites• Central administrative systems• Purchasing requirements, vendor relationship• Open source projects• Enforcement and consequences• Accessibility alongside accommodation• Implementation timeline not complete
Web accessibility = usability
• All audiences benefit
• Content easier to access with portable devices
• Content easier to re-use
• Content better organized
• Simpler links, digestible chunks
• Download times reduced
Project: Evaluate accessibility of CC websites• Diagram depicting relationship between 4
evaluation methods including– Automated 508 evaluation– Manual 508 evaluation– Simulated user evaluation– Actual user evaluation
• Automated and manual 508 evaluation procedures are page-based evaluations
• Simulated user evaluation and actual user evaluations are process-based
• All methods evaluate both accessibility and, to some degree, usability
• Overall <5% of all pages evaluated complied with all Section 508 criteria
• Notable results:– 35% of images lacked meaningful alt text– 100% of data tables lacked headers– 100% of frames lacked titles– 87% of use of scripts was not accessible– 91% of forms objects were not labeled– 97% of pages lacked skip navigation links
Graph of Section 508 Manual Evaluation
Results
508 Manual Check Results(% of all relevant sets of pages n=150)
100
97
91
100
87
4
100
100
1
4
35
4
5
20
2
42
3
5
8
80
96
97
96
23
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
p) Timed Response (n=1)
o) Skip Nav Links (n=136)
n) Forms (n=78)
m) Scripts - Link to accessible version (n=11)
l) Scripts -- Asst. Tech Equivalent (n=60)
k) Text-Only (n=5)
j) Flickering (n=137)
i) Frames (n=4)
h) Logical Level Headers (n=0)
g) Data table Headers (n=6)
f) Client-side image maps provided (n=0)
e) Image maps: Redundant Links (n=0)
d) CSS (n=132)
c) Color (n=142)
b) Multimedia (n=0)
a) Images (n=136)
Checkpoint (# pages included)
No Implimentation - significant barrier Partial Implimentation Full Implimentation
NA
NA
NA
NA
Guidelines governing web design
Sample = 701 Community Colleges
Requirements regarding web accessibility
• Guidelines governing web design– 71% of colleges have guidelines for web design– 28% either don't have guidelines or don't know
• Requirements regarding web accessibility– 50% reported having web accessibility requirements
– 29% do not have web accessibility requirements– 49% either don't have requirements or don't know if they do
• Of the 29% who do not have web access. requirements,
– 30% plan to implement them in next year– 36% do not plan to implement in next ye
• POINT: A surprising 50% of colleges have some sort of web accessibility policy or statement of intent.
• Sample=701 Community Colleges
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
# Responses
Yes No Don't know No Response
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
# Responses
Yes No Don't know No Response
Survey*: 50% of institutions with
Web Accessibility Requirements
Website Evaluations**: <5% Web Pages met
Section 508 Web Accessibility Standards
*N = 701 community colleges**N = 150 web pages from 30 community college websites
What do the web accessibility requirements cover?
• Of the 50% who have web accessibility requirements,– 84% of policies cover student services pages– 66% of policies cover individual department/ faculty pages– 75% cover online course content including distance
learning courses– 82% cover ALL college web pages
• POINT: More directly under control of central administration (webmaster), more likely to be covered by web policy; as opposed to under control of departments or individual faculty
Dept /
Faculty
Distance
Learning
Student
Services
ALL
0 20 40 60 80 100
%
Barriers to implementation
Costs & Staffing
Lack of technical support
Lack of knowledge /
training
Lack of awareness
Attitude; Disregard
Lack of support
from administrati
on
Lack of Faculty
Involvement
• Costs• Staffing• Training• Technical support• Awareness• Attitude• Administrative support• Faculty Involvement
WebAIM*8-Step Implementation Model
1. Gather baseline information2. Gain top level support3. Organize a web accessibility committee4. Define a standard5. Create an implementation plan6. Provide training and technical support7. Monitor conformance8. Remain flexible through the changes
*www.webaim.org
The worst thing that
could happen is a policy
that sits on the shelf
• Legally vulnerable
• Not showing a good faith effort
Every institution is different
Your starting point:• Size of website• Number & job roles of
designers & contributors
• Administrative structure & support
• Attitudes
Will affect:• Sequence of events• Timeline• Who gets involved• ???
So you have a policy…
What’s Next?
Step 5: Implementation Plan
• Establish timelines
• Set priorities
• Delegate responsibilities
• Monitor progress
• Document!!!• Example: http://www.wact.missouristate.edu/plan.htm
During Implementation…
Example
Step 6: Training & Technical SupportTraining
• Short term: – Awareness of the need– Understanding of the User Perspective*– Design techniques – Know your audience
• Different skill levels • Different needs (faculty, staff, web designers, students)
• Long term– Incorporate accessibility into existing training
programs*www.webaim.org
Step 6: Training & Technical Support
• Training: Questions– In-house or outsource– Live or online; Delivery format– Frequency– Target audiences– Topics– Updating
Step 6: Training & Technical Support
• Technical Support– Add to job responsibilities of existing staff
(performance evaluation criteria)• Web designers, technical support specialists,
web managers, instructional designers
– Services (in-house, contract)• Video captioning, transcription• Compliance testing / user testing
– Listserv
Step 7: Monitor Conformance
• Compliance testing procedures & frequency– Automated– Manual– User testing
• Let everyone know about your commitment to accessibility– Add statement to your home page– Provide avenue for user to report accessibility
barriers
Step 7: Monitor Conformance
• Plan for sustainability– Include in job description of webmaster, CIO or
hire accessibility consultant– Schedule yearly checks of all web content &
distribute reportsBe sure accessibility criteria is included in all
procurement contracts– Establish relationship with Disability Services
OfficeAim for Systemic Change
Step 8: Remain flexible
Changes in:• standards• personnel• technologies
May necessitate:• new training• new leadership• revised
implementation plan
LEADERSHIP
The most obvious person may not be the best person
• Passionate• Understands disability
issues• Leadership qualities
